{"operation":"document","citation":"CPF 120121016W","title":"COLUMBIA GAS TRANSMISSION, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2012-06-25","effective_on":null,"summary":"CLOSED warning letter citing 192.481(a), 192.603(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120121016w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120121016w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120121016w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120121016W","body":"Warning Letter involving COLUMBIA GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.481(a),  192.603(b). The case was opened on 2012-06-25 and is reported as closed as of 2012-06-25. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120121016W_Warning Letter_06252012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120121016W/120121016W_Warning%20Letter_06252012.pdf\n\n120121016W_Warning Letter_06252012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120121016W/120121016W_Warning%20Letter_06252012_text.pdf\n\n120121016W_Warning Letter_06252012_text.pdf\n\nU.S. Department 820 Bear Tavern Road, Suite 103\nOf Transportation West Trenton, NJ 08628\nPipeline and 609.989.2171\nHazardous Materials\nSafety Administration\nWARNING LETTER\nOVERNIGHT EXPRESS MAIL\nJune 25, 2012\nMr. William T. Kilpatrick, VP Operations\nNiSource Gas Transmission & Storage\n1700 MacCorkle Avenue, SE\nCharleston, WV 25314\nCPF 1-2012-1016W\nMr. William T. Kilpatrick:\nDuring the week of March 12, 2012, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nColumbia Gas Transmission’s gas transmission pipelines in the Cumberland, MD area.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violation(s) are:\n1. 192.603 General provisions\n(b) Each operator shall keep records necessary to administer the procedures\nestablished under §192.605.\nColumbia Gas Transmission (CGT) failed to keep records necessary to administer the procedures\nestablished under 192.605. Pursuant to 192.615(b)(2), the operator must train the appropriate\noperating personnel to assure that they are knowledgeable of the emergency procedures and\nverify that the training is effective.\nDuring the inspection, the PHMSA Inspector asked CGT to describe how they ensure that the\nappropriate personnel are knowledgeable of emergency procedures and to determine the\neffectiveness of the training. In response, CGT provided training records and emergency plan\ntest questions. The records did not specifically show that appropriate personnel were\nknowledgeable of the emergency procedures and that the applied training was effective.\n\n\n\nCPF 1-2012-1016W\n2. 192.481 Atmospheric corrosion control: Monitoring.\n(a) Each operator must inspect each pipeline or portion of pipeline that is exposed\nto the atmosphere for evidence of atmospheric corrosion, as follows:\nIf the pipeline is located: Then the frequency of inspection is:\nOnshore At least once every 3 calendar years, but with intervals not\nexceeding 39 months\nCGT failed to inspect each onshore pipeline or portion of pipeline that was exposed to the\natmosphere for evidence of atmospheric corrosion at least once every 3 calendar years, but with\nintervals not exceeding 39 months.\nFor pipeline, PL-1804 from L-5727-5726 to L-7166, Waynesburg Yard to Waynesburg CS, CGT\ndid not inspect for evidence of atmospheric corrosion at least once every three calendar years, at\nintervals not to exceed 39 months. The inspection due on 8/1/2011 was performed on 9/13/2011.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000\nfor each violation for each day the violation persists up to a maximum of $1,000,000 for any\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item(s) identified in this letter.\nFailure to do so will result in Columbia Gas Transmission Corp being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, please send your correspondence to:\nMr. Byron Coy, PE, Director, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103, W.\nTrenton, NJ 08628 and in your correspondence please refer to CPF 1-2012-1016W. Be advised\nthat all material you submit in response to this enforcement action is subject to being made\npublicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nByron Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n120121016W\n_Warning Letter_06252012 Page 2 of 2","truncated":false,"body_characters":4841}